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Capital ContributionsThis section explains the tax treatment of contributions from shareholders and nonshareholders. Paid-in capital. Contributions to the capital of a corporation, whether or not by shareholders, are paid-in capital. These contributions are not taxable to the corporation. However, contributions to a corporation in aid of construction or any other contribution as a customer or potential customer is taxable to the corporation. Basis. The basis of property contributed to capital by a shareholder is the same as the basis the shareholder had in the property increased by any gain recognized on the exchange. The basis of property contributed to capital by a person other than a shareholder is zero. If a corporation receives a cash contribution from a person other than a shareholder, reduce the basis of property acquired with the money during the 12-month period beginning on the day it received the contribution by the amount of the contribution. If the amount contributed is more than the cost of the property acquired, then reduce, but not below zero, the basis of the other properties held by the corporation on the last day of the 12-month period in the following order.
Reduce the basis of property in each category to zero before going to the next category. There may be more than one piece of property in each category. Base the reduction of the basis of each property on the ratio of the basis of each piece of property to the total bases of all property in that category. If the corporation wishes to make this adjustment in some other way, it must get IRS consent. The corporation files a request for consent with its income tax return for the tax year in which it receives the contribution. |
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